accordance with the scheme then in place, sick companies with
outstanding export obligations in such situations were granted extended time to
complete the export obligations ... March 31, 2018 the appellants had completed about 67% of their
outstanding export obligation of 70%. According to the appellants, the appellant
company was liable
contracts to
hedge its exposure against foreign currency fluctuation risks
towards outstanding export receipts and ECBs, entire details
available at page 131 of the paper ... commercial
expediency and necessity. The taxpayer gave detail of forward
contract outstanding as on 31.03.2008 in Notes to the Accounts of
17 ITA No.1638
Technologies
Ltd. on export sales filter and ignored Appellant's contention on
reliability of export sales data, effect of outstanding receivables ... income from exports to
total sale filter of 75% by ignoring appellants contentions on
reliability of export sales data, effect of outstanding receivables
and geographical
clearly stated the
outstanding of M/s.Valley exports were not mentioned in Ex.P12 and the
outstanding should be paid fully before making ... having loan in
the name of M/s.Valley Exports pending with outstanding. Thereafter,
Ex.P13 reply was sent
monies
to M/s. Radha Exports during the Financial Years 2001-
2002, 2002-2003 and 2003-2004 and amount outstanding
from the said the partnership ... Appellant
Company and further acknowledged that the amount outstanding
from the erstwhile firm M/s. Radha Exports to the Respondent
Finance Act
2012. Therefore, even the outstanding receivable partake the character
of capital financing and consequently, overdue outstanding is an
"international transaction‟. The natural ... repatriation of exports proceeds for SEZ, it
cannot be said that for determining ALP of export receivable, which
becomes capital financing, if outstanding is beyond
rupee would be part of the
export turnover in the year of receipt?
b) Whether export sale proceeds received in accordance with and in
terms ... respect of such export on deferred
payment terms. The assessee obtained finance from Allahabad Bank against
3
the outstanding dues of 90 per cent
addition on account of notional
interest on export receivables. The Ld. AR of the assessee
submits that outstanding receivables are not
international transaction ... Crore on yearend conversion
of its outstand forward contracts, details of export
invoices related to these contracts as on 31 st March 2009
were furnished
month on the
outstanding amount. The assessee was required to give working of interest on late
realization or non-realization of export proceeds during ... receivables as on
1.4.2009 which were outstanding for more than 60 days; and export proceeds not realized
within 60 days from the date of invoice
receivables was closely linked to the 'international transaction' of export
and since the profit earned by the assessee as a percentage of cost ... decision
of the Tribunal in deleting the notional interest on outstanding amount of
export proceeds realized belatedly cannot be faulted."
21. So, when
